Privacy Policy

Welcome to DueSure NG, registered with the CAC as DueSure Support Limited with registration RC 9916662 referred hereinafter as ("we," "our," or "us"). We operate as an automated Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) Due Diligence and Screening Web Platform designed to support Designated Non-Financial Businesses and Professions (DNFBPs) in Nigeria.

We are committed to protecting the privacy and security of personal data in strict compliance with the Nigeria Data Protection Act (NDPA) 2023 and regulations issued by the Nigeria Data Protection Commission (NDPC). This Privacy Policy explains how we collect, process, store, and protect information when you use our platform.

To provide statutory AML/CFT screening and verification services, we collect and process the following categories of data:

1. Account & Organization Information: Legal business name, CAC RC/BN/IT number, SCUML registration number, corporate address, billing email, phone number, and user credentials (names, corporate email addresses, and encrypted passwords).

2. Subject Screening Data: Names, dates of birth, nationalities, and corporate identifiers of individuals or entities submitted by your compliance team for screening against sanctions lists, Politically Exposed Persons (PEPs) registries, and adverse media.

3. Tokenized Identity Data: When identity verification (NIN/BVN) or corporate registry checks (CAC) are triggered, we process verification request metadata and return cryptographically masked tokens and validation flags. We do not store raw, unmasked National Identification Numbers (NIN) or Bank Verification Numbers (BVN) on our local multi-tenant database servers.

4. Technical Telemetry & Audit Logs: IP addresses, browser types, session timestamps, and immutable audit logs capturing platform interactions for regulatory compliance.

In accordance with Section 25 of the NDPA 2023 and the statutory mandates of the MLPPA 2022, we process personal data under the following lawful bases:

1. Legal Obligation: Assisting DNFBPs in fulfilling statutory Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) obligations required by respective regulators.

2. Explicit Consent: Captured by your organization from your end-customers/clients prior to executing identity and background screenings.

3. Legitimate Interest: Ensuring network security, preventing fraud, maintaining tamper-evident audit trails, and improving our matching algorithms.

We do not sell, trade, or rent personal data. Information is disclosed strictly under the following operational frameworks:

1. Licensed Identity & Data Partners: Authorized API aggregators operating under strict data processing agreements to interface with key stakeholders.

2. Payment Processors: For secure subscription billing and credit transactions.

3. Regulatory Authorities: When legally mandated by court order, statutory subpoena, or direct lawful directive from the NFIU, EFCC, or SCUML under the MLPPA 2022.

1. Encryption: All data at rest is encrypted using HTTPS, JW”RS256”, and data in transit is secured via TLS 1.3.

2. Tenant Isolation: PostgreSQL database schemas enforce strict Row-Level Security (RLS) to ensure complete data segregation between competing DNFBP organizations.

3. Data Localization: Primary databases and server infrastructure reside within secure, compliant data environments adhering to NITDA and NDPA cloud data localization standards.

Under the NDPA 2023, data subjects have the right to:

1. Request access to their personal data held within audit archives (subject to statutory anti-money laundering tipping-off prohibitions).

2. Request rectification of inaccurate personal records.

3. Object to processing or request deletion, except where retention is mandated by federal anti-money laundering record-keeping laws (which require compliance records to be retained for a minimum of 5 years).

For inquiries, complaints, or exercise of data privacy rights, contact our DPO at:

Email: [email protected]

Address: 4 Webilor Street, 2^nd Pipeline, RMP, Rivers State